.Practice Book § 61–11 provides in relevant part: “(a) Except where otherwise provided by statute or other law, proceedings to enforce or carry out the judgment or order shall be automatically stayed until the time to take an appeal has expired. If an appeal is filed, such proceedings shall be stayed until the final determination of the cause....”DiLieto, who, by the time the court was considering Daly's motion, had been substituted as the plaintiff, claimed that, under Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 304–305, 472 A.2d 316 (1984), a party who recovers offer of judgment interest under § 52–192a is entitled to postjudgment interest under § 37–3b as a matter of law. She also argued that, to the extent that Carrano holds that wrongful detention is an element of an award of interest under § 37–3b, that case was wrongly decided because it conflicts with Gionfriddo and, furthermore, that, in contrast to § 37–3a, § 37–3b does not contain language explicitly or implicitly conditioning an award of interest on a finding that money was wrongfully detained.

Our courts have consistently held that prejudgment interest is to be awarded by the trial court when a valid offer of judgment is filed by the plaintiff, the offer is rejected by the defendant, and the plaintiff ultimately recovers an amount greater than the offer of judgment after trial. See, e.g., Civiello v. Owens-Corning Fiberglass Corporation, supra; Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 472 A.2d 316 (1984); Paine Webber Jackson Curtis, Inc. v. Winters, supra; Gillis v. Gillis, 21 Conn. App. 549, 575 A.2d 230, cert. denied, 215 Conn. 815, 576 A.2d 544 (1990); Edward Denike Tree Co. v. Butler, 21 Conn. App. 366, 573 A.2d 349 (1990); Crowther v. Gerber Garment Technology, Inc., 8 Conn. App. 254, 513 A.2d 144 (1986); Kusha v. Respondowski, 3 Conn. App. 570, 490 A.2d 1014 (1985). Moreover, an award of interest under 52-192a is mandatory, and the application of "52-192a does not depend on an analysis of the underlying circumstances of the case or a determination of the facts."

ECKER, J. The sole issue in this appeal is whether the trial court properly awarded postjudgment, offer of compromise interest to the plaintiff, Kelly Services, Inc., under General Statutes § 52-192a and Practice Book § 17-18. We conclude that the trial court's award of postjudgment, offer of compromise interest was improper under our holding in Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 307–308, 472 A.2d 316 (1984), and therefore reverse in part the judgment of the trial court. General Statutes § 52-192a provides in relevant part: "(a) Except as provided in subsection (b) of this section, after commencement of any civil action based upon contract or seeking the recovery of money damages, whether or not other relief is sought, the plaintiff may, not earlier than one hundred eighty days after service of process is made upon the defendant in such action but not later than thirty days before trial, file with the clerk of the court a written offer of compromise signed by the plaintiff or the plaintiff's attorney, directed to the defendant or the defendant's attorney, offering to settle the claim underlying the action for a sum certain. ... If the offer of compromise is not accepted within thirty days and prior to the rendering of a verdict by the jury or an award by the court, the offer of compromise shall be considered rejected and not subject to acceptance unless refiled.

Connecticut case law also makes it clear that interest under § 52-192a(b) terminates as of the date of the final judgment. Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 308, 472 A.2d 316, 320 (1984). The issue raised in this appeal is what is "the amount recovered" to which the 12% interest is applied.

The "money damages" clause in § 52-192a (a) has been partially interpreted. In Gionfriddo v. AVIS Rent A Car System, Inc., 192 Conn. 301, 308, 472 A.2d 316 (1984), the Supreme Court held that personal injury claims fall within the purview of § 52-192a. See also Foley v. Huntington Co., 42 Conn. App. 712, 741, 682 A.2d 1026 (1996); cert. denied, 239 Conn. 931 (1996).

. . . Crowther v. Gerber Garment Technology, Inc., 8 Conn. App. 254, 267, 513 A.2d 144 (1986); Kusha v. Respondowski, 3 Conn. App. 570, 574, 490 A.2d 1014 (1985). . . . This interest is mandated when the amount recovered is greater than or equal to the offer of judgment; see General Statutes § 52-192a (b); and that amount can include interest and attorney's fees; Crowther v. Gerber Garment Technology, Inc., supra, 270-71; as well as double or treble damages. Gionfriddo v. Avis Rent a Car System, Inc., 192 Conn. 301, 307, 472 A.2d 316 (1984)." Gillis v. Gillis, 21 Conn. App. 549, 554, 575 A.2d 230, cert. denied, 215 Conn. 815, 576 A.2d 544 (1990).

The offer of judgment is to be compared to the amount that the plaintiff "has recovered," which includes compensatory interest. Gillis v. Gillis, 21 Conn. App. 549, 556, 575 A.2d 230, cert. denied, 215 Conn. 815, 576 A.2d 544 (1990) (concluding that trial court improperly denied offer of judgment interest on § 37-3a interest portion of verdict); see also Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 304-305, 472 A.2d 316 (1984) ("it is the total judgment that is the relevant [basis] for comparison"). The trial court likewise awarded the plaintiff offer of judgment interest against EI in the amount of $830,377.

If we were to agree with the interpretation of the defendants and the trial court, we would, in fact, hinder the purpose of this provision: the promotion of settlements in cases so as to unclog an overloaded docket. See Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 304, 472 A.2d 316 (1984); Verrastro v. Sivertsen, 188 Conn. 213, 223-24, 448 A.2d 1344 (1982). See also testimony of Richard Bieder, Esq., Hearings before Joint Standing Committee on the Judiciary, Pt. 3, 1977 Sess., p. 691 (hearings on Senate Bill 805, enacted as Public Acts 1977, No. 77-269).

Statutory damages trebling the jury’s award and attorneys fees awarded as punitive damages constitute "recovery" for offer-of-judgment award purposes. Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 307 (1984); Kregos v. Stone, 88 Conn.App. 459, 467 (2005). Furthermore, to reduce the amount recovered by collateral sources and then preclude the plaintiff from consideration of other recovery such as costs awarded defies common sense as well as the spirit and the purpose of the offer-of-compromise statutes.

In interpreting § 52-192a in the context of negligence claims, our supreme court has indicated that prejudgment interest runs to the date of judgment. Gionfriddo v. Avis Rent A Car System, Inc., 192 Conn. 301, 308 (1984); see also Camp, Dresser and McKee v. Technical Design Associate, 937 F.2d 840, [ 937 F.2d 840], 844 (2nd Cir. 1991), citing Gionfriddo. Additionally, our appellate court has observed approvingly the award of interest under § 52-192a to the date of judgment as distinguished from the earlier date of jury verdict. Edward Denehey Tree Co. v. Butter, 21 Conn. App. 366, 369 (1990).